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announces that the IRS and Treasury intend to issue regulations under Section 367(b) to address certain triangular reorganizations involving foreign corporations. The regulations will apply to triangular reorganizations where either the parent corporation or its subsidiary are foreign and where the subsidiary acquires from the parent, in exchange for property, parent stock that is used to acquire the stock or assets of a target corporation. The regulations will treat the transfer of property from the subsidiary to its parent as a distribution of property under Section 301(c) and make corresponding adjustments.
YELLOW SPRINGS -- Antioch University's board of governors has set a June 30 deadline for the transfer of university assets to the corporation that would become an independent Antioch College. Antioch University closed Antioch College on June 30, 2008, because of declining enrollment and other problems. Since August 2008, however, the university has been negotiating with the Antioch College Continuation Corp. to create an Antioch College that would be independent of the university. We are continuing on a timeline that would meet the June 30 date," said Richard Detweiler, president of the Great Lakes College Association and chairman of a task force of alumni and trustee representatives working to create a new Antioch.
Proposed regulations under IRC section 368 indicate that partnerships can be the recipients of transfers of stock or assets for the purposes of the continuity-of-business-interest and continuity-of-interest requirements for tax-free reorganizations. If the reorganization is followed by a transfer of stock or assets to a partnership, the reorganization will not be disqualified if the transferring corporation has a substantial interest in the partnership's management or business. Prior to the proposed regulations, there was no indication that such transfers to partnerships were allowable.
The Federal Deposit Insurance Corporation (the ``FDIC'' or the ``Corporation'') is issuing a final rule (``Final Rule'') that implements part of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the ``Dodd-Frank Act'' or the ``Act''), which permits the Corporation, as receiver for a financial company whose failure would pose a significant risk to the financial stability of the United States (a ``covered financial company''), to enforce contracts of subsidiaries or affiliates of the covered financial company despite contract clauses that purport to terminate, accelerate or provide for other remedies based on the insolvency, financial condition or receivership of the covered financial company. As a condition to maintaining these subsidiary or affiliate contracts in full force...
... the Corporation as receiver must either: Transfer any supporting obligations of the covered financia... under the contract (along with all assets and liabilities that relate to those supporting ob...
... legal entity from you and any movement of assets, which includes cash, from your corporation to you.... Transfer of Assets to the Corporation . The Income Tax Act ...
... Code of 1954 (IRC), which grants a corporation a deduction for taxes imposed on its shareholders ... a plan of liquidation and distributed its assets, including the cattle feed, to its shareholders. R... there will be no gain or loss on the transfer of assets to a controlled corporation in such a si...
This document contains final and temporary regulations. These regulations eliminate one of two exceptions to the coordination rule between asset transfers and indirect stock transfers for certain outbound asset reorganizations. The regulations also modify the third exception to the coordination rule for certain outbound exchanges so that this exception is consistent with the remaining asset reorganization exception. In addition, the regulations modify, in various contexts, procedures for obtaining reasonable cause relief. Finally, the regulations implement certain changes with respect to transfers of stock or securities by a domestic corporation to a foreign corporation in a section 361 exchange. The regulations primarily affect domestic corporations that transfer property to foreign co...
...person transfers assets to a foreign corporation (direct asset transfer) i...
... owns the institution or the parent corporation of that entity, acquires or loses the ability to c...(2) The transfer of the controlling interest of stock of the instit...(6) A transfer of assets that comprise a substantial portion of the educati...
The FDIC is proposing a rule (``Proposed Rule''), with request for comments, that implements section 210(c)(16) of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the ``Dodd-Frank Act'' or the ``Act''), codified at 12 U.S.C. section 5390(c)(16), which permits the Corporation, as receiver for a financial company whose failure would pose a significant risk to the financial stability of the United States (a ``covered financial company''), to enforce contracts of subsidiaries or affiliates of the covered financial company despite contract clauses that purport to terminate, accelerate, or provide for other remedies based on the insolvency, financial condition or receivership of the covered financial company. As a condition to maintaining these subsidiary contracts in full forc...
... the Corporation as receiver must either: transfer any supporting obligations of the covered financia... under the contract (along with all assets and liabilities that. Page 18128. relate to those ...
...(2) A debtor has created a shell corporation before receiving a loan, or after receiving a loan... an entity, or has reorganized, transferred ownership of, or otherwise changed in some manner ...(3) Assets used in the entity's operation include assets pled...
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